left to my own devices – occasional thoughts on higher education

Image from Royal Museums Greenwich, Wikimedia Commons // Public Domain | Royal Museums Greenwich, Wikimedia Commons // Public Domain

Whether the current challenges that higher education faces are either catastrophic or merely bad, we all know that the last time things were like this for universities the song that defined that year was a Number 1 that doesn’t exactly augur well.

As universities seek to navigate these challenges, of course the usual rhythms of academic life continue.  The second teaching term/semester is getting into full swing.  Research is being carried out, written up and published.  And of course the Office for Students is consulting on something.

And this should be a big one: the draft OfS Strategy, 2025-30. 

Emerging from the savaging of the House of Lord’s Industry and Regulators Committee’s report, and the tamer but still pointed Independent Review from David Behan, this should be the start of a new chapter for OfS.

someone’s talking but who’s listening?

It’s easy to be sceptical about such consultation processes, and for good reason.  For years the sector has felt that OfS regarded consultations as one of the ‘dignified’ rather than ‘efficient’ elements of its regulatory approach, with little if any impact on the final version of any document on which OfS was consulting.

After a year or two of this following OfS’s establishment in 2018, some in the sector even developed a perverse pleasure in reading OfS’s analysis of consultation responses, just to see specifically how OfS regarded us all as wrong in what we had said in our consultation responses.

This was undoubtedly an important contributor to the poor sector/regulator relationship identified in both the House of Lords’ and Behan reports.  Behan’s report, though, thought it identified green shoots emerging in the relationship between OfS and the sector; recommended that these be nurtured and developed; and given that shortly after his report was published Behan was appointed Interim Chair of OfS, we have to assume that the new gardener is taking great care with these tender plants (to beat the metaphor to death).

So perhaps on this occasion consultation responses may have more concrete impact.

to regulate is to choose – or not

And the draft OfS Strategy has a huge amount for the sector to engage with.

The government accepted the Behan report’s recommendation [p.14] that OfS needed to reduce its strategic objectives and focus on four key priorities: financial sustainability; quality; protecting public money; regulating in the interests of students. These four priorities run through the new draft Strategy, but reading the draft Strategy the sheer scope of activity stated or implied is unlikely to feel to the sector to be much like prioritisation.

The draft Strategy perhaps acknowledges this by being clear that ‘each year, we will set out our planned activity in an annual business plan calibrated to reflect the resources we have available’ [p.17]. At the same time, the draft makes repeated references to OfS ‘working with ambition and pace’ – references likely to prompt one or two nervous glances within and among universities.

Some will be wondering whether an already over-stretched sector, going through significant retrenchment, will have the resource and bandwidth for pace and ambition across the breadth of agenda the draft Strategy sets.

They may not find it much consolation that OfS will set this pace according to the level of their own resource. Universities may perhaps even wonder whether OfS’s level of resource, paid for by providers, should be delivering the same level and speed of efficiency savings as those that providers are needing to achieve currently.

the question

In the draft Strategy there are a number of good things (e.g. model student contract; revised approach to quality and standards); bad things (e.g. implied focus on undergraduate provision, and oversight of postgraduate); optimism bias (e.g. the much mythologised ‘lead indicators’, despite the disaster that has been Data Futures); and things that make you go hmmm (e.g. the focus on financial sustainability that is essential, but within an individual provider, market-based framework rather than the broader sector-wide perspective that’s needed – though that’s HERA’s fault rather than OfS’s).

Those are things that will be picked up in individual consultation responses.  I wanted to focus here on a broader question.

Is developing a new OfS Strategy at this point indicative of an organisation, or even a sector, in denial?

while they were rearranging the deck chairs

In some ways, being asked for opinions on an OfS Strategy for the period 2025 to 2030 feels a bit like being invited to join the Captain of the Titanic in his quarters shortly after the ship has hit the iceberg, to help plot a revised course to New York necessitated by some inconveniences the voyage had recently experienced.  Nice in some ways (it’s good to have some acknowledgment of your navigation skills), but something that feels a bit redundant.

Harsh?  Possibly.  But consulting on a new OfS Strategy at this point denies, for me, three crucial things.

sector reform

Last November Bridget Phillipson announced a government review of higher education.  We know the government’s five priorities for higher education that will drive that review.  But that review itself has barely got under way – the intention is that this will lead to the publication of a plan for higher education sector reform in summer 2025.

While acknowledging the ongoing links and communication between the government, DfE and OfS, surely a plan from an incumbent government (and one with a majority of a size that means that, despite the fever dreams of the right wing media, it is unlikely to be out of power in the next three to four years) for higher education reform must have a significant bearing on what is needed from OfS between now and 2030?

Is now really the time for OfS to be plotting a course to 2030?

growth

The draft Strategy is also fairly silent on a critical issue.

There is an ongoing debate about the role of regulation, and how it interacts with broader economic and political objectives, particularly economic growth.

Focusing solely on the UK dimension of this, the government is clearly highlighting the need for regulation not to obstruct needlessly the economic growth it is desperately seeking.  This is not a simple issue or debate; but it is one that feels largely absent from the OfS draft Strategy in any depth, despite OfS regulating one of the UK’s most successful economic sectors and OfS being subject to the same Growth Duty as other UK regulators.

A draft Strategy that is not preceded by, or at least encompasses, a proper debate on this is flawed.

the impact of regulation

A couple of weeks ago, George Osborne was discussing on his podcast the legislation currently under discussion to set up a regulator for football.  I tend to agree more often with his podcast partner than with Osborne, but Osborne drew a picture (from 54:46) of the ways in which once a regulator has been established it draws its remit and activities ever wider (often for well-intentioned reasons) until it starts undermining the success of the sector it regulates. I suspect that a few of us who have worked in the post-2018 English higher education sector may feel the resonance of Osborne’s description.

Not long after listening to this, I read a recent article by Nigel Thrift, that had echoes of the same issues.  Thrift writes about what he views as the ‘sheer weight of regulation and compliance that now exists’ for universities, describing OfS as a ‘whale, seemingly intent on turning universities into large schools or colleges’ [p.2].  He cites approvingly Alex Usher’s view on such issues from a Canadian perspective:

Canada has no REF, no TEF, no KEF.  We have nothing resembling the Office for Students.  External quality assurance, where it exists, is so light touch as to be basically invisible.  This does not stop us having four or five universities in the Global top 100, eight in the top 200, and twenty or so in the top 500 … I am pretty sure Canada probably leans a little too far the other way on regulation, and we should learn a bit from the UK, particularly on external quality assurance.  But what the UK can and should learn from Canada is that it is possible to put together a world-class higher education system based not on external regulation but rather on the intrinsic motivation of professional pride and hard work of the academic and non-academic staff who work there

Alex Usher, ‘Senate House Notes’, 20 Nov. 2024

Thrift and Usher point to the conversation we should be having now in English higher education, about the shape and extent of regulation.

the real questions

Is the regulatory structure for higher education in England founded on the right principles and approach?  Have we created a regulatory system with its own internal logic and momentum that damages rather than protects higher education at a system level?  How does the regulatory system align with and support broader national objectives?

Those are the questions that need to be asked and answered now.  Not what we think of a draft OfS Strategy for 2025-30.

The latter conversation doesn’t acknowledge the current situation and challenges.  As I said: in denial.